NAIC Model Regulation 275 State-By-State Adoption
As states adopt the new NAIC Model Regulation 275, a new annuity standard of care rule becomes effective. This new “best interest” standard, which replaces the old suitability standard, impacts the sales process requiring producers to use new point-of-sale form requirements, producer disclosures, and documentation obligations.
New Required NAIC Training (LIMRA/RegEd)
All producers will be required to complete a new training course related to compliance with the new model. Depending on whether the producer has already completed the 4-credit annuity training course in the past, he or she must also complete either (1) a new 1-credit hour training course or (2) a newly revised 4-credit course which incorporates the new model. Training courses are available through external training platforms such as RegEd or LIMRA. Per the rule, we will NIGO business if the training is not completed within the states required timeline in each state where the new model has been adopted.
Below is a state-by-state grid that outlines the date these changes take effective.
| States with an adopted new annuity standard of care rule requirement | Effective date of rule* | Training required by date |
|---|---|---|
| Alabama | 1/1/2022 | 7/1/2022 |
| Arizona | 12/31/2020 | 7/1/2021 |
| Arkansas | 7/8/2021 | 1/1/2022 |
| Connecticut | 3/1/2022 | 9/1/2022 |
| Delaware | 8/1/2021 | 2/1/2022 |
| Idaho | 7/1/2021 | 1/1/2022 |
| Iowa | 12/31/2020 | 7/1/2021 |
| Maine | 1/1/2022 | 7/1/2022 |
| Michigan | 6/29/2021 | 12/29/2021 |
| Montana | 10/1/2021 | 4/1/2022 |
| Nebraska | 1/1/2022 | 1/1/2022 |
| North Dakota | 1/1/2022 | 7/1/2022 |
| Ohio | 8/14/2021 | 8/14/2021 |
| Rhode Island | 4/1/2021 | 10/1/2021 |
| Texas | 9/1/2021 | 1/1/2022 |
| Virginia | 9/1/2021 | 3/1/2022 |
* New forms required on effective date: Producer Disclosure Form (32931) and Best Interest Attestation Form (32921Z)